
Female Was Not Required To Show That She Was Similarly Qualified To Male Employee Who Replaced Her
Jama M. Vincent, a female employee who was replaced by a male employee on a gas pipe installation crew, brought suit under Title VII of the Civil Rights Act of 1964, alleging that her employer discharged her on account of her gender. The district court held that Vincent could not establish a prima facie case of gender discrimination because she could not show that she was as qualified for her position as her male replacement. Consequently, the district court granted summary judgment in favor of her former employer.
On appeal, the 6th Circuit reversed, holding that to establish a prima facie case of gender discrimination, a plaintiff who can prove that she was replaced by a member of the opposite sex need not show that she possesses qualifications similar to those of her replacement. Because Vincent had established that she was replaced by a man, the fact that he was certified in plumbing and she was not did not preclude her from establishing a prima facie case.
Vincent v. Brewer Co.
The 6th Circuit Court of Appeals’ jurisdiction includes Michigan, Ohio, Kentucky and Tennessee.